June 15, 2006

M. Frank Mordacq
Directeur de l'Agence de Modernisation de L'Etat

Mr. Director,

On behalf of the Computer & Communications Industry Association (CCIA) I thank you for this opportunity to comment on the Référentiel Général d'Intéropérabilité, in particular Section 4.1.4, which deals with adoption of OpenDocument Format (ODF) as a government standard in France.

CCIA has, for more than 30 years, been the leading proponent of “open markets, open systems and open networks.” We are an international, nonprofit association of computer and communications industry firms that employ more than 600,000 workers and generate annual revenues in excess of $200 billion. Our open source initiative, the Open Source and Industry Alliance (OSAIA), represents the interests of open-source developers and users around the world. Thus we greet with great enthusiasm your proposed adoption of ODF.

Competition

As you know, electronic documents are typically stored in proprietary file formats, formats that cannot be guaranteed to work with more than one developer's word processor, spreadsheet, graphics package or database program. Such exclusivity naturally leads to a dependency on one or two suppliers who cannot be relied upon to insure that documents, once produced, will remain accessible to all. Indeed, once “locked in” to one or two vendors, governments may effectively lose control of public records in their possession.

Real problems caused by proprietary formats

Worries over long term access to documents are real. The world's most popular office software, for instance, often fails to open documents produced before 1996. What's more, other, older documents from other companies are sometimes completely indecipherable because the technical specifications used to produce them are not available. ODF's entirely open nature solves all of these problems.

This situation was problematic when the Internet and desktop computing were largely separate. Convergence of the two have, nonetheless, made it intolerable. The OpenDocument Format (ODF) offers an answer to the problem.

ODF is owned by the Organization for the Advancement of Structured Information Standards (www.oasis-open.org) and was created by multiple companies and organizations, CCIA members among them. Since the technical underpinnings of documents saved in ODF are available to everyone, developers can produce software that will, in turn, generate documents that are entirely compatible with competing products. This new lingua franca is vitally important to government and citizens alike. For the first time in memory, they will be able to switch from office software made by one maker to that of another without worrying about incompatibilities between the two. The International Organization for Standardization (ISO), and International Electrotechnical Commission recognized the versatility of ODF when they declared it an international standard in May.

Open government

Free peoples can remain so only when their laws and history are available to all. Governments thus have a basic responsibility to assure that their documents are open and will remain so. There can be no such guarantee as long as the technologies used to produce those documents are in the hands of a few. ODF is and will remain free because the process used to develop it was entirely transparent, because it is entirely free of royalties or other encumbrances, and because it is completely supported by many vendors and not-for-profit organizations.

Innovation

Your decision to adopt ODF will do much to encourage innovation inside and outside of government. Open standards minimize barriers to entry, ensure full, fair and open competition, and compel vendors to compete on quality, design, service, and performance, rather than the design of incompatible file formats.

Customer Control

Your Agency has plainly recognized the importance of these basic principles. By committing to ODF, you have cast aside the parochial interests of the few and replaced them with something more important: competition on the merits. Your agency, we believe, has embraced the vanguard of technology with this latest initiative and will reap the benefits. Rather than remaining dependent on a handful of vendors, governments like yours can assume the normal posture of customers in a competitive market and demand from suppliers the features that they need. In short, open standards such as ODF improve the welfare for government, business and consumers alike.

ODF is based on an entirely non-proprietary implementation of XML which itself gives users unsurpassed flexibility in the interchange of data across organizations. ODF, together with other XML technologies, will give France unprecedented flexibility and control over public documents, allowing for more and better communications between departments and with the general public.

Standards and Networks

ODF follows a long line of non-proprietary innovation in technology. Examples are numerous, and include the full suite of Internet standards as well as XML. The nonproprietary nature of these standards means that everyone is free to use them. This openness has proven essential to their widespread adoption and ultimately resulted in the creation of Internet- and Web-based software, services, and business models.

France, Denmark, Norway, Thailand and the state of Massachusetts have all taken note of these facts. We are active in these debates and look forward to spreading the good news about ODF and open standards broadly. CCIA and dozens of other companies and organizations are fanning out across the globe to assure timely acceptance of this and other vitally important, open standards.

We wish again to offer our firmest support for your actions regarding ODF. Do not hesitate to contact us if there is anything we can do to be of further service.

Sincerely,

Ed Black
President